ML20214G967
| ML20214G967 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 11/26/1985 |
| From: | Harwell E, Kidd M, Sauer R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082840729 | List: |
| References | |
| I-85-346-SQN, NUDOCS 8605290555 | |
| Download: ML20214G967 (18) | |
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TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF
-NSRS INVESTICATION REPORT No. I-85-346-SQN EMPLOYEE CONCERN: XX-85-054-001
SUBJECT:
QC HOLDPOINT SIGNOFF VIOLATION DATES OF INVESTIGATION: SEPTEMBER 23-30, 1985
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INVESTICATOR:
E.[F.HARWELL QiTE /
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REVIEWED BY:
4 R. C. SAUER' Date APPROVED BY:
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BACKCROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern as received by the Quality Technology Company (QTC)/ Employee Response Team (ERT). The concern of record, as summarized on the Er.ployee Concern Assignment Request Form from QTC and identified as XX-85-054-001, stated:
"Sequoyah - QC holdpoints are signed off by craftsmen (craft known) performing the work.
Personal friendship between inspectors and craft allow this to occur without being reported. Time frame is between 1979 to 1984. No specifics provided."
Further information was requested from the ERT follow-up group regarding whether this concern involved Construction or Nuclear Power-type holdpoints, type work, and crafts involved. QTC relayed that the CI
'.dentified the craf ts as Construction fitters and welders. Although the CI did not identify the type work, it is assumed that it dealt with welding during pipe installation. The CI also identified another individual (individual A) who was familiar with the above practice.
II.
SCOPE A.
The scope of the investigation is defined by the concern of record which entails determining if QC holdpoints had been signed off by craftsmen because of their friendliness with inspectors during the period 1979 to 1984.
B.
Construction procedures and instructions were reviewed to determine the dccumentation required for welding, fitup, and QC holdpoint signoff that were applicable for the timeframe of interest. A random review of computer weld data cards was performed, including operation checklists and individual inspections, for welds performed during the subject concern time period. Interviews were conducted with 18 personnel of various welding-related backgrounds including fitter welders, fitters, fitter foremen, welding engineers, weld 1
inspectors, lead inspectors, records clerk, and supervision. Also interviewed was the individual named by the CI as having knowledge
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concerning this type occurrence.
III.
SUMMARY
OF FINDINGS A.
Requirements and Commitments I
1.
ANSI Standard B31.1.0 (1967), " Power Piping" - Governed installation and inspection requirements for piping systems q
other than TVA Safety Class A, B, C, and D.
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2.
ANSI Standard B31.7 (1969) and 1970 Addendum, " Nuclear Power:
Piping"
- overned installation and inspection requirements for-G TVA Safety Class A, B, C, and D piping systems.
3.
CONST-QAP 9.01, " Assignment'of Special Processes."
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TVA General Construction Specification G-29, '* Process 4.
Specifications for Welding, Heat Treatment, Nondestructive Examination',.and Allied Fleid Fabrication Operations."
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5.
TVA 47B333 series drawings " Weld and Nondestructive Examination t{
Procedure Assignment."
B.
Findings 1.
The Sequoyah Construction Procedures and Instructions were f
evaluated and determined that adequate controls were written to i
prohibit signoff of QC holdpoints by anyone other than a j
qualified, certified inspector. The use of computerized j
operation checklists, individual inspection data cards, and i
shift inspection logs provided a crosscheck to ensure that j
inspections u-e properly done by qualified individuals. When holdpoints missed, corrective actions were taken to rectify.
b 2.
Construction Procedure W-3 " Weld Procedure Assignment and I,
Welding Surveillance" did allow the foreman to verify preheat on j
welds on subsequent shiftwork after it had been released for l'
welding by the Weld Inspection Unit. He denoted this on the
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back of the operation checklist.
Also, he could note any additional welders that worked on the weld joint. This normally j
applied to heavy support welds. However, per discussions with welding engineers and lead inspectors for critical pressure j
l boundary welds, an inspector was present almost on a continual i
basis.
In addition, to assure compliance with welding T'
parameters, a general welding surveillance of each work area was j
required twice per shift by Standard Operating Procedure 3
SOP-700, " Weld Surveillance".
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A random sample of weld data cards was compared to the operation d*
checklist and no discrepancies were found.
J 4.
For nonsafety class welds, the craft foreman was and is 7
y-responsible for assuring that correct procedure was used, correct filler material was used, and a sound weld was installed.
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5.
Af ter the weld data cards were turned in, the QC Records Unit j{
checked the cards for proper signoff by a qualified individual with up-to-date certifications and signature verification.
Any
'j discrep,ancies were returned to the Welding Inspection Unit for correction or resolution.
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's IV.
C0tJCLUSIO!!S AtJD RECOMMEtIDATI0tJS
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A.
The allegation appears to be unsubstantiated for the following reasons:
e The individual identified by the concerned individual as having knowledge concerning this problem did not acknowledge seeing any craft personnel signing any QC documentation or know of any instances where it occurred.
o The weld dotamentation system with all its crosschecks and reviews would have a high probability of not allowing the signoff of a QC holdpoint by an unqualified individual.
None of the people interviewed knew of any instance where a e
craftsman signed off on a QC holdpoint.
Since inspections were performed by the next available e
inspector, assurance of getting a particular inspector (personal
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friend) could not happen with any degree of certainty.
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B.
The concerned individual may have witnessed the signing of the j
operation checklist on the back for preheat verification and additional welder assignments (as permitted by procedures) and j
misconstrued this as a QC holdpoint signoff. The operation checklist was considered, at that time, to be an information tool to j
assist the foreman in controlling the work and not a QC record, u
h except when additional welders were noted on the back for completing the weld.
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0.QLOYAll - WELD SIGNOFF Cl!RONOLOGY k
before Jan. 1977 Welding was governed by M-3, " Welding Surveillance and Weld Procedure Assignment," and M-7, " Erection and Documentation Requirements for Piping Systems" January 31, 1977 Joe Wilkins, New Project Construction Engineer, mandated that the welding records be computerized.
W-3, " Weld Procedure Assignment and Welding Surveillance," was issued to use computer data cards for welding documentation.
February 11, 1977 M-3 deleted.
April 25, 1977 Standard Operating Procedure SOP-700, " Welding Surveillance," was issued that required each rod shack inspection team to perform a random surveillance of welding in their area twice cach shift and document results.
October 14, 1977 W-3 was revised to include an operation checklist that identified welding procedure, size and configuration of weld joint, and QC holdpoints. Holdpoints had to be signed off on the checklist before next operation was to commence. The operation checklist remained in the area of the weld.
Decenber 4, 1978 W-3 revised to allow craft foreman to verify preheat on subsequent shifts and sign back of checklist. However, the initial inspection, fitup release, and preheat verification was done by the Weld Inspection Unit inspector.
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l DOCUMENTS REVIEWED IN INVESTIGATION I-85-346-SQN AND REFERENCES 1.
SUP Construction Procedure M-3, Revision 2, dated May 1, 1975, " Welding Surveillance and Weld Procedure Assignment" 2.
SNP Construction Procedure M-7, Revision 14, dated November 19, 1976,
" Erection and Documentation Requirements for Piping Systems" 3.
SNP Construction Procedure W-3, Revision 3, dated December 4, 1978,
" Weld Procedure Assignment and Welding Surveillance" 4.
SNP Standard Operation Procedure SOP-700, Revision O. dated April 25, 1977,
" Weld Surveillance" 5.
SNP Inspection Instruction No. 63, Revision 13, dated May 20, 1983,
" Piping Inspection" 6.
TVA General Construction Specification G-29, " Process Specifications for Welding, Heat Tecat, Nondestructive Examination, and Allied Field Fabrication Operations" dated March 9, 1983 i
7.
TVA General Construction Specification G-43, " Support and Installation of Piping Systems in Category I Structures," Revision 8, dated August 8, i
1985 i
i 8.
Microfilm copies of computer weld data cards for various NDE examination i
and operation checklist cards i
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9.
Standard Operation Procedure SOP-550, Revision 0, dated December 14, 1977, i
" Review of Quality Assurance Records" l
Note:
Document Revision Histories were also evaluated for the entire timeframe in question.
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12T TIE CC CZ2:1 ASSIC'.?.ftr 75.0,'*23 T?m:SM!r.** :705Z7. T50092 TO: Director - NSIS ERT has receired the I=ployee concern identified belev, and has assi; ed the i=dicated ca:egory and priori:7:
Conca n J X*(-85-054-001 1
Priority:
Ccnfidentialit7:
TES NO (!&E) 39 Category:
Superrisor Notified:
TIS X NO NCC Z.*J. SAI'I""? RE* t" 23 vre Sequoyah-QC holdpoints are signed off by craftsmen (craft known) per-Concern:
forming the work. Personal friendship between inspectors & craft allow this to occur without being reported. Time frame is between 1979 to 1984. No specifics provided.
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DEI NSRS has assi;=ed responsibility for investigation of the above concern to:
ERT NSRS/ERT NS?3
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OTHERS (S?EC ??)
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TVA EMPLOYEE CONCERNS REPORT NUMBER: I-85-636-SQN SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUMBER: 0 TITLE: TVA Manufacture of a Dravo ASME-Class Spool Piece REASON FOR REVISION: N/A 5
SUMMARY
STATEMENT: N/A PREPARATION PREPARED BY:
Original Signed By R. M. Bateman 11-06-86 SIGNATURE DATE REVIEWS PEER:
Original Signed By J. E. Rose 11-06-86 SIGNATURE DATE
[TEpICALREVEWONLY TAS:
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n6sdx SIGNATURE DATE L
CONCURRENCES i
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SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
h fb N'hhb N/A ECSP M5NA'$ER DATE MANAGER OF NUCLEAR POWER DATE
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CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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WELDING PROJECT
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SON SPECIFIC EMPLOYEE CONCERNS DATE 11/6/86
SUBJECT:
SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -
SUMMARY
OF WP ENGINEERING EVALUATION CONCERN CONSIDERED: XX-85-068-007 I
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APPROVED BY k
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This package summarizec the actions taken'by the Welding Project (WP) to evaluate and disposition the subject SON-specific. employee concern which was previously evaluated by NSRS/DTC/ERT and summarized in WP Phase I and Phase II Ii
- reports.
f The Welding Project analyzed each SON-cpecific employee concern (Attachment 2) i to determine the statement (s).being voiced by these individuals.
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l These statement were then evaluated both individually and collectively to
-lj develop issues.
Each issue was then incorportated into the WP review activities of Phase I, I
"Rrocedural Assessment" and Phase II, " Procedural Implementation."
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,' Du'Iing Phase I, each issue was analy ed against requirements of the applicable l'
3i OA program, policies, NSRS/OTC/ERT Investigation Reports, and other relevant
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information to determine if program elements were deficient when evaluated I2i against upper tier requirements.
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1 Phase II consisted of a sample reinspection of hardware and independent j
program audit by Bechtel.
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2n each area analyzed by Bechtel, the auditors found no objective evidence to "1
j substantiate.the employee concerns considered. The following areas directly related to employee concern were in'vestigated by the audit teams i
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1.
Welder qualification and attendant records a
2.
Welder qualification and attendant on-the-job-training 3.
Welding inspections 4.
Welding inspectors training prograns 5.
Weld material traceability 6.
Welding inspections by craft personnel 7.
Weld material control it N.
Each of these areas was investigated by the auditors for both construction and 1
operations phases. In all cases, there was no objective evidence to substantiate the employee concerns. The audit report concludes that both construction and operations phases have had and now have a functioning Welding 3
Quality Assurance Program which meets code, standard, and regulatory 1
requirements and that the employee concerns considered were found to be unsubstantiated and without technical merit.
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i The results of the reinspection program at SQN also give another, additional
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verification of the Welding Quality Assurance Program for both construction and operations phases and serve to establish additional confidence in the accuracy and implementation af these programs through hardware inspections and attendant document reviews.
In all cases, the components an( items werr; found to be acceptable upon initial reinspection or found to be acceptable after engineering analysis.
The WP analysis of SQN Specific Employee Concerns supplemented by the independent Bechtel Audit, reinspection of installed components and systems, and independent (NSRS) overview and investigations has not revealed any significant or generic inadequacies in the welding programs for either the construction or operations phase at SQN which have been directly identified through the Employee Concern Program. The Employee Concern Program has simply reiterated problems which have been or are now being resolved through existing corrective action programs in the overall Nuclear Quality Assurance Program.
A summary analysis of the WP evaluations and recommendations is included in.
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SUMMARY
OF SQN SPECIFIC EMPLOYEE CONCERNS REVIEWED BY WELDING PROJECT l
EMPLOYEE CONCERN NUMBER ISSUE WP ACTION l
XX-85-088-003 Alterations to Welder Not substantiated by ERT I
Qualification Records in Report XX-85-088-003 of Knoxville 3/8/86 (Attachment 3).
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I' XX-85-124-001 Burial of Electrode Stubs Not safety-related. No action required.
I XX-85-086-003 Box Anchor Design Substantiated by NSRS Report I
Deficiency.
I-85-560-SQN (Attachment 3).
d WP concurs with report recommendations.
XX-85-069-003-R1 Acceptance of Previously Not Substantiated by NSRS Rejected NDE Items Report I-85-738-SQN (Attach-ment 3).
WP concurs with report recommendations.
SQM-5-001-001 Uncertified Welder Foreman Substantiated by WP Evaluation SQM-5-001-002 Performing Preweld Report WP-16-SQN (Attachment WBM-5-001-002 Inspections 3).
Interim corrective (Also Listed in actions are being the Generic formulated.
Closure is Summary) based on these actions.
Additional corrective actions may be implemented.
XX-85-068-007 Manufacture of Dravo Spool Not substantiated by NSRS Piece REPORT I-85-636-SQN (Attachment 3).
XX-85-069-001 Inadequate OJT-Records for The general issue of XX-85-069-001-R1 ISI and QC Personnel for NO inadequate OJT-records was l
XX-85-069-X05 substantiated by NSRS Report I
XX-85-069-007 I-35-373-NPS (Attachment 3).
No falsification of records was substantiated. WP con-r' curs with report recommen-l dations.
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EMPLOYEE CONCERN NUMBER ISSUE WP ACTION SQM-6-005-001 Craft Welder Incapable of SQM-6-005-001 was SQM-6-005-X02 Mahing Proper Welds substantiated; SQM-6-005-X02 was not substantiated by NSRS Report I-86-115-SQN (Attach-I ment 3).
WP concurs with report.
4 XX-85-013-001 E309 Electrode Used to Weld This is an acceptable E316 Steels practice.
ERT investigated
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in ERT Report XX-85-013-001, 4
l dated 3/22/85 (Attachment 3).
WP concurs.
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Q XX-85-041-001 Improper Weld Rod Used in Not substantiated by NSRS 4
Diesel Generator Building Report I-85-756-SQN 4
(Attachment 3).
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XX-85-049-001 Welder Certifications XX-85-049-001 was XX-85-049-X03 Updated Without Meeting substantiated as it relates
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Requirements to Welder Continuity Requiro-
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ments. This had previously been identified by NO in an audit. XX-85-049-XO3 was not j
4 substantiated. Details and recommendations are given in is D
NSRS Report I-85-135-SQN k
(Attachment 3).
WP concurs with I-85-135-SQN-01 through
-03 and recommends they be o
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closed based on the WP-Bechtel Audit of SQN in Key Elements 4.0, 5.0, and 17.0 (Attachment 4).
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XX-85-054-001 QC Holdpoint Sign-Off Not substantiated by NSRS Violation Report I-85-346-SQN I
(Attachment 3).
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1 XX-85-065-001 Performance of Remote Visual Not substantiated by NSRS Inspections Report I-85-750-SQN
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(Attachment 3).
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EMPLOYEE CONCERN NUMBER ISSUE WP ACTION XX-85-083-001 SQN Weld Inspections not as Not substantiated by NSRS Strict as WBN Report I-85-652-SQN (Attachment 3).
XX-85-098-001 Laminated Pipe in Unit 2 Not safety-related. Not Condenser. This issue is substantiated by WP Evaluation j
also on the Generic Summary Report WP-18-SQN (Attachment 3).
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3 Il XX-85-100-001 Improper Weld Repair on an Not substantiated by ERT fi Undetermined Number of Report XX-85-100-001, dated Welds 3/5/86 (Attachment 3).
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XX-85-101-006 Welder Certification for ERT Report XX-85-101-006 the Construction Era (Attachment 3) with NSRS s
Recommendations indicates
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that this concern is sub-stantiated. WP takes excep-j tion to this ERT Report based on subsequent information provided in Attachment 4.
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exceptions, recommen-D dations, and basis for h
closure were discussed with
'I NSRS as documented in Attach-h ment 5.
WP recommends this Fj concern not be substantiated and that it be closed based i
V on the WP-Bechtel Implemen-I tation Audit, Key Elements j
4.0, 5.0, 17.0 (Attachment 6).
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XX-85-102-011 NDE Inspectors Cannot Write Not substantiated by NSRS f
Notice of Indications for Report I-85-735-SQN Preservice-Related Defects (Attachment 3).
XX-85-108-001 Socket Welds Not Inspected Not substantiated by NSRS XX-85-108-002 Report I-85-776-SQN (Attachment 3).
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10/16/66 (LMPLOYLE CONCERNS) 8 8K"
' - "8 11: 25:45 CA1 ISSUE PLANT PRIORITY ORG OVC EGG INSP SD RD GD 10
CONCERN-------
1 XX-85-068-007
""YWORDS:
NOT WELD RELATED PROB: XXXXX ocOUOYAH - TVA MAY HAVE MANUFACTURED A SPOOL PIECE TO REPLACE, UNDER ASME SECTION XI. A DRAVO ASME-CLASS SPOOL PIECE.
WHEN THE SPOOL PIECE WAS REPLACED. THE CODE NAMEPLATE FROM THE DRAVO SPOOL PIECE WAS REMOVED, AND AFFlXED TO THE TVA MANUFACTURED SPOOL. THIS MAY HAVE BEEN NOTED BY A COGNIZANT INSPECTION INDIVIDUAL (POSITION KNOWN). AND NOT REPORTED DUE TO THE INDIVIDUAL NOT WANTING TO GET INVOLVED.
CONSTRUCTION DEPT. CONCERN. Cl HAS NO FURTHER INFORMATION.
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STAT:
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TECHNICAL COMMENTARY:
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1 WEl. DING PROJECT I
SQN SPECIFIC EMPLOYEE CONCERNS Y
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ATTACHMENT 3 NSRS REPORT I-85-636-SQN 8
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'NITED STATES 0 9VERNMENT Memoranclum Tsxxzsses vattsy auritonirr 71 f
TO
- H. L. Aber..rt,mbie, Site Director. Sequoy.th Nuclear Plant FROM
- K. W. Whitt, Director of huelear Safety Review Staff, E3A8 C-K Q,] s DATE
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SUBJECT:
NUCLEAR St.fETY RE'JIEW STAl'F INVESTIGATION REPORT TRANSMITTAL Transmitted herein is h::RS Report No.
I-85-636-SON Subject TVA MANUFAC'fURE OF A DRAVO ASME-CLASS SPOOL PIECE Concern No.
7X_;05-068-007 No response or corrective action is required for this report.
It is being transmitted to you for information purposes only.
Should you have any questions, please contact R. C. Sauer at telephone 2277 Recommend ReW etab 11ty Determination:
Yes No X
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Director, NSRS/ Designee
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RCS:JTH Attachment ec (Attachment):
R. P. Denise, LP6N35A-C R. J. Criffin, SQN E-18 l
G. B. Kirk, SQN D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant Eric Sliger, LP6N48A-C J. H. Sullivan, SQU W. F. Willis, E12B16 C-K (4) h
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